# ENBRIDGE ENERGY, LIMITED PARTNERSHIP — Corrective Action Order

- **operation:** document
- **citation:** CPF 320105008H
- **title:** ENBRIDGE ENERGY, LIMITED PARTNERSHIP — Corrective Action Order
- **source type:** enforcement
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** historical
- **official:** true
- **published on:** 2010-07-28
- **effective on:** Not available
- **summary:** CLOSED corrective action order.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-enforcement-320105008h.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-enforcement-320105008h.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-enforcement-320105008h
- **source url:** https://primis.phmsa.dot.gov/enforcement-data/case/320105008H
**body:**

Corrective Action Order involving ENBRIDGE ENERGY, LIMITED PARTNERSHIP. The dataset does not identify a cited regulation for this case. The case was opened on 2010-07-28 and is reported as closed as of 2015-03-20. Open the official case record for notices, responses, orders, and the latest status.

Official case documents:

320105008H_CAO Amendment_09222010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320105008H/320105008H_CAO%20Amendment_09222010.pdf

320105008H_CAO Amendment_09222010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320105008H/320105008H_CAO%20Amendment_09222010_text.pdf

320105008H_CAO_07282010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320105008H/320105008H_CAO_07282010.pdf

320105008H_CAO_07282010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320105008H/320105008H_CAO_07282010_text.pdf

320105008H_Closure_03202015.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320105008H/320105008H_Closure_03202015.pdf

320105008H_Closure_03202015_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320105008H/320105008H_Closure_03202015_text.pdf

320105008H_Notice of Proposed CAO Amendment_09172010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320105008H/320105008H_Notice%20of%20Proposed%20CAO%20Amendment_09172010.pdf

320105008H_Notice of Proposed CAO Amendment_09172010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320105008H/320105008H_Notice%20of%20Proposed%20CAO%20Amendment_09172010_text.pdf

320105008H_Region CAO Status Report Restart Plan Disapproved_08102010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320105008H/320105008H_Region%20CAO%20Status%20Report%20Restart%20Plan%20Disapproved_08102010.pdf

320105008H_Region CAO Status Report Restart Plan Disapproved_08102010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320105008H/320105008H_Region%20CAO%20Status%20Report%20Restart%20Plan%20Disapproved_08102010_text.pdf

320105008H_Restart Plan Disapproved_08102010.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320105008H/320105008H_Restart%20Plan%20Disapproved_08102010.pdf

320105008H_Restart Plan Disapproved_08102010_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/320105008H/320105008H_Restart%20Plan%20Disapproved_08102010_text.pdf

320105008H_CAO Amendment_09222010_text.pdf

SEP 22 2010
VIA CERTIFIED MAIL AND FACSIMILE TO: (713) 653-6711
Mr. Terry McGill
President
Enbridge Energy Partners, L.P.
1100 Louisiana, Suite 3300
Houston, TX 77002
Re: CPF No. 3-2010-5008H
Amendment to the July 28, 2010 Corrective Action Order
Dear Mr. McGill:
In light of your company’s waiver of a hearing, enclosed is a Amendment to the Corrective
Action Order issued on July 28, 2010, as proposed in the a Notice of Proposed Amendment to
the Corrective Action Order issued on September 17, 2010. Your receipt of this Amendment
constitutes service of that document under 49 C.F.R. § 190.5.
Please direct any questions on this matter to David Barrett, Director, Central Region, Office of
Pipeline Safety, PHMSA, at (816) 329-3800.
Sincerely,
Jeffery Wiese
Associate Administrator
For Pipeline Safety
Enclosures: Amendment to the Corrective Action Order
Copy of 49 C.F.R. § 190.233



U. S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, DC 20590
_________________________________
)
In the Matter of )
)
Enbridge Energy Partners, L.P., ) CPF No. 3-2010-5008H
)
Respondent. )
_________________________________)
AMENDMENT
TO THE CORRECTIVE ACTION ORDER
Background and Purpose
On July 28, 2010, under authority of 49 U.S.C. § 60112, the Associate Administrator for Pipeline
Safety, Pipeline and Hazardous Materials Safety Administration (PHMSA), issued a Corrective
Action Order (CAO) to Enbridge Energy Partners, L.P. (Enbridge or Respondent), finding that
the continued operation of Respondent’s Line 6B extending approximately 286 miles from
Griffith, Indiana to the U.S.−Canadian border would be hazardous to life, property, and the
environment unless certain corrective actions were taken. PHMSA issued the July 28, 2010
CAO (Original CAO) in response to a failure on Line 6B near Marshall, Michigan that was
reported by Enbridge on July 26, 2010 (Marshall Failure). The failure resulted in an estimated
release of 19,500 barrels of crude oil. The spilled oil entered the Talmadge Creek and the
Kalamazoo River. PHMSA initiated an investigation of the Marshall Failure which is ongoing.
The Original CAO set forth preliminary findings based upon PHMSA’s initial investigation of
the Marshall Failure and requires, among other things, that the line remain out-of-service until
repairs under a pre-approved restart plan are completed and restart of the line is approved by the
Director, Central Region, PHMSA. The CAO also imposes an ongoing 20 percent pressure
reduction, requires inspections and evaluations of additional sections of the pipeline to determine
if conditions similar to those associated with the Marshall Failure were likely to exist elsewhere
on Line 6B, and requires the development, implementation, and completion of an integrity
verification and remedial work plan before a return to full pressure operations will be permitted.
1
1 In the Matter of Enbridge Energy Partners, L.P., Corrective Action Order (CPF No. 3-2010-5008H) dated July
28, 2010 (Original CAO).



2
While the root cause and all contributing factors to the Marshall Failure have not yet been
established by the National Transportation Safety Board, additional information about the failure
and the condition of Line 6B has become available to PHMSA since the Original CAO was
issued as a result of PHMSA’s ongoing investigation. This information includes a visual
examination of the failed pipe section under laboratory conditions, the results of six anomaly
investigation digs and repairs, and a review of previous in-line inspection results, and an
extensive amount of other technical information concerning the pipeline.
On September 17, 2010, based on this additional information, PHMSA issued a Notice of
Proposed Amendment to the Original CAO (Notice) notifying Respondent of additional
preliminary findings of the agency’s investigation and proposing that Respondent take certain
additional corrective measures with respect to Line 6B. On September 21, 2010, Enbridge
responded to the Notice. Enbridge did not contest the Notice, stated its intent to comply with the
Notice, and waived its opportunity for a hearing.
Additional Preliminary Findings
The preliminary findings in the Original CAO are hereby amended by adding the following
additional preliminary findings:
• The timeline of discovery of the failure is as follows:
07/25/2010 5:56 PM Scheduled shutdown of Line 6B initiated by Enbridge.
07/25/2010 5:58 PM Actual time of pressure drop on pressure logs.
07/25/2010 9:32 PM First of nine 911 odor complaints in area.
07/25/2010 10:54 PM Odor investigation closed by Marshall Township Fire Dept.
07/26/2010 11:18 AM Consumers Energy reports odor to Enbridge Control Center.
07/26/2010 11:45 AM Enbridge personnel confirm leak at rupture site.
07/26/2010 11:45 AM Enbridge emergency response is initiated.
07/26/2010 1:33 PM Enbridge notifies National Response Center – Report #948903.
• On June 4, 2008, Enbridge received the final report on the 2007 MFL inspections results
from the tool vendor. The final report indicated a total of 140 anomalies requiring action
within 180 days, of which 26 were repaired and 114 remain.
• The 2009 in-line inspection using ultrasonic technology identified 250 anomalies, 35 of
which were immediately repaired, and 215 remain. The remaining anomalies are
between mileposts 650 and 753.
• Following the removal and inspection of the failed pipe, Enbridge performed additional
anomaly investigation digs at Mile Posts 611.72, 619.57, 654.42, 654.71, and 682.72. In
some cases, these investigations revealed the presence of anomalies which were repaired.
• On August 21, 2010, an engineering analysis of the deformation anomaly under the St.
Clair River at Mile Post 751.22 performed by a third-party laboratory was provided to
PHMSA.



3
• PHMSA secured the services of Oak Ridge National Laboratory to provide an
independent review of Enbridge in-line inspection data and support for PHMSA’s review
of Enbridge actions. Oak Ridge is analyzing the growth rates of certain identified
anomalies.
• On January 21, 2010, PHMSA issued a Warning Letter to Enbridge related to the
disconnection of five hydrogen permeation internal corrosion monitors installed on Line
6B, one in January 2006, two in May 2006, and two in October 2007. Enbridge reported
that the monitoring systems were disconnected due to communications/instrumentation
problems. The warning noted that Enbridge was not able to prove to PHMSA that its
interim measures properly managed the threat of internal corrosion.
• On January 26, 2010, PHMSA issued an Advisory Bulletin reminding hazardous liquid
pipeline operators of the importance of prompt and effective leak detection capability in
protecting public safety and the environment.
Finding of Hazardous Condition
Section 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action
Order, including amendments, after reasonable notice and the opportunity for a hearing,
requiring the operator of a pipeline determined to pose a hazard to take corrective actions to
protect the public and the environment. These may include the suspended or restricted use of a
pipeline facility, physical inspection, testing, repair, replacement, or other action, as appropriate.
The basis for making a determination that a pipeline facility is or would be hazardous, requiring
corrective action, is set forth both in the above-referenced statute and 49 C.F.R. § 190.233, a
copy of which is enclosed.
After evaluating the all available information on the safety of Line 6B including the foregoing
additional preliminary findings, and considering the nature of the Marshall Failure, the age of the
pipe involved, the manufacturer, the hazardous nature of the product transported, the pressure
required for transporting such product, and the ongoing investigation to determine the root cause
of the failure, I find that the continued operation of the Line 6B without additional corrective
measures would be hazardous to life, property, and the environment.
Accordingly, PHMSA hereby issues this Amendment to the CAO requiring the additional
actions specified herein be taken to protect life, property, and the environment. The additional
actions set forth in this Amendment to the CAO are in addition to the actions set forth in the
Original CAO and do not suspend or eliminate the requirements of the Original CAO, unless
otherwise specifically provided herein.
Amendments to Required Corrective Action
Pursuant to 49 U.S.C. § 60112 and 49 C.F.R. § 190.233, Enbridge Energy Partners, L.P. is
ordered to comply with this Amendment to the CAO and take the following additional corrective
actions with respect Line 6B. Enbridge shall comply with the following amendments:
1. Restart Plan. Item 2 of the Original CAO is amended by adding paragraphs (D)−(F) as
follows:



4
(D) Incorporate the actions set forth in PHMSA’s letter of August 10, 2010 including
additional anomaly investigations and hydrostatic testing into the plan.
2
(E) Incorporate the actions set forth in PHMSA’s letter of September 3, 2010 into the
plan.
3
(F) Enbridge must secure the services of a third-party monitor to provide monitoring
during the restart process. Such monitoring shall include monitoring from the
Edmonton Control Center as well as review of start-up procedures and
documentation, pipe design criteria, operating parameters and procedures, process
equipment, monitoring equipment, and SCADA.
2. Integrity Verification and Remedial Work Plan. Item 5 of the Original CAO is
amended by adding paragraphs (G)−(J) as follows:
(G) The plan must include project plans and schedules for the repair of all remaining
anomalies identified for action from the 2007 and 2009 in-line inspections and
identified to PHMSA on September 16, 2010 in accordance with 49 C.F.R. Part
195, but no later than 180 days of restart. Specifically:
i. The 40 remaining 180-day conditions from the 2007 in-line inspection must be
repaired within 180 days of restart beginning with the anomalies identified in
Table 6, of the July 15, 2010, Long Term Pressure Reduction Notification.
ii. The 114 remaining 180-day conditions must be repaired within 180 days of
restart.
(H) The plan must include project plans and schedules for the repair of all other
remaining pipe anomalies identified for action in the July 15, 2010 Notification to
be completed in accordance with 49 C.F.R. Part 195 but no later than 180 days of
restart.
(I) The plan must include the performance of both a transverse field in-line inspection
capable of identifying metal loss and an ultrasonic technology in-line inspection
capable of detecting cracks on Line 6B. The in-line inspections must be performed
according to the following schedule:
i. The in-line inspection tools must be run within 14 days of restart.
ii. The tool vendor’s initial report on anomalies meeting immediate repair criteria
shall be provided to PHMSA within 30 days of completion of the in-line
inspections.
2 Letter from David Barrett, Director, Central Region, PHMSA to Terry McGill, President, Enbridge Energy
Partners, L.P. dated August 10, 2010.
3 Letter from David Barrett, Director, Central Region, PHMSA to Shaun Kavajecz, Manager, Pipeline Safety
Compliance, Enbridge Pipelines (Lakehead) LLC dated September 3, 2010.



5
iii. Immediate repairs as defined by 49 C.F.R. 195.452(h)(4) shall be made within
14 days of discovery regardless of whether such anomaly met a previous
repair criterion.
iv. The tool vendor’s final report on all anomalies shall be provided to PHMSA
within 90 days of completion of the in-line inspections and anomalies
requiring repair shall be repaired in accordance with 49 C.F.R. Part 195 but no
later than 180 days of discovery.
v. The new in-line inspections results must be integrated into results of prior tool
runs to reprioritize the focus and schedule of the integrity verification and
remedial work plan as necessary.
(J) The plan must include project plans and a schedule for the complete replacement of
the pipe in the entire St. Clair River crossing to be completed within one year of
restart. Provide such plans and schedules to both PHMSA and the National Energy
Board of Canada. To the extent delays arise due to obtaining required permits, the
Regional Director may grant an extension of time upon written request.
The actions required by this Amendment to the CAO are in addition to and do not waive any
requirements that apply to Line 6B under the Original CAO or to Respondent’s pipeline system
under 49 C.F.R. Parts 190 through 199, as applicable, or any other Order issued to Respondent
under authority of 49 U.S.C. § 60101 et seq., or under any other provision of federal or state law.
After receiving and analyzing additional data in the course of this investigation, PHMSA may
identify other corrective actions that need to be taken. In that event, Respondent will be notified
of any additional measures required and further amendment of the CAO will be considered. To
the extent consistent with safety, Respondent will be afforded notice and an opportunity for a
hearing prior to the imposition of any additional corrective measures.
___________________________________ __________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

320105008H_Notice of Proposed CAO Amendment_09172010_text.pdf

SEP 17 2010
VIA CERTIFIED MAIL AND FACSIMILE TO: (713) 653-6711
Mr. Terry McGill
President
Enbridge Energy Partners, L.P.
1100 Louisiana, Suite 3300
Houston, TX 77002
Re: CPF No. 3-2010-5008H
Proposed Amendment to the July 28, 2010 Corrective Action Order
Dear Mr. McGill:
Enclosed is a Notice of Proposed Amendment to the Corrective Action Order issued on July 28,
2010, immediately following the spill of your Lakehead Line 6B in Marshall MI. It stipulates
additional requirements to ensure the safety and efficacy of this pipeline upon an eventual and
gradual interim restart of the line. Service is being made by certified mail and facsimile. Your
receipt of this Notice constitutes service of that document under 49 C.F.R. § 190.5.
The Amendment incorporates previous written communications from PHMSA regarding the
requirements of any restart plan. In addition, the Amendment requires Enbridge to secure the
services of a third-party monitor to provide monitoring during the restart process.
With respect to the integrity verification and remedial work plan that is due on September 26,
2010, your company’s plan must include specific deadlines for repairs. Specifically, your
company’s plan must include project plans and a schedule for the total replacement of the pipe in
the entire St. Clair River crossing within one year of restart. We understand that your company
must obtain certain permits to complete this work. We strongly urge you to proceed
aggressively with permitting and replacement. In addition, PHMSA orders Enbridge to repair
every already identified anomaly in Line 6B that meets the repair criteria within 180 days.
These repairs should be made as soon as practical and focus on replacing portions of the line
with multiple and significant colonies of anomalies. Finally, Enbridge must undertake at least
two assessments of the entire Line 6B within 14 days of any restart, and take aggressive action to
repair any newly identified anomalies, as required in the timeframes designated by 49 C.F.R.
Part 195.
PHMSA will hold your company to the terms of the Amended Corrective Action Order,
including the deadlines and will propose maximum fines per penalty, per day according to
federal regulations for any violations.



Please direct any questions on this matter to David Barrett, Director, Central Region, Office of
Pipeline Safety, PHMSA, at (816) 329-3800.
Sincerely,
Jeffery Wiese
Associate Administrator
For Pipeline Safety
Enclosures: Notice of Proposed Amendment to the Corrective Action Order
Copy of 49 C.F.R. § 190.233



U. S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
OFFICE OF PIPELINE SAFETY
WASHINGTON, DC 20590
_________________________________
)
In the Matter of )
)
Enbridge Energy Partners, L.P., ) CPF No. 3-2010-5008H
)
Respondent. )
_________________________________)
NOTICE OF PROPOSED AMENDMENT
TO THE CORRECTIVE ACTION ORDER
Background and Purpose
On July 28, 2010, under authority of 49 U.S.C. § 60112, the Associate Administrator for Pipeline
Safety, Pipeline and Hazardous Materials Safety Administration (PHMSA), issued a Corrective
Action Order (CAO) to Enbridge Energy Partners, L.P. (Enbridge or Respondent), finding that
the continued operation of Respondent’s Line 6B extending approximately 286 miles from
Griffith, Indiana to the U.S.−Canadian border would be hazardous to life, property, and the
environment unless certain corrective actions were taken. PHMSA issued the July 28, 2010
CAO (Original CAO) in response to a failure on Line 6B near Marshall, Michigan that was
reported by Enbridge on July 26, 2010 (Marshall Failure). The failure resulted in an estimated
release of 19,500 barrels of crude oil. The spilled oil entered the Talmadge Creek and the
Kalamazoo River. PHMSA initiated an investigation of the Marshall Failure which is ongoing.
The Original CAO set forth preliminary findings based upon PHMSA’s initial investigation of
the Marshall Failure and requires, among other things, that the line remain out-of-service until
repairs under a pre-approved restart plan are completed and restart of the line is approved by the
Director, Central Region, PHMSA. The CAO also imposes an ongoing 20 percent pressure
reduction, requires inspections and evaluations of additional sections of the pipeline to determine
if conditions similar to those associated with the Marshall Failure were likely to exist elsewhere
on Line 6B, and requires the development, implementation, and completion of an integrity
verification and remedial work plan before a return to full pressure operations will be permitted.
1
1 In the Matter of Enbridge Energy Partners, L.P., Corrective Action Order (CPF No. 3-2010-5008H) dated July
28, 2010 (Original CAO).



2
While the root cause and all contributing factors to the Marshall Failure have not yet been
established by the National Transportation Safety Board, additional information about the failure
and the condition of Line 6B has become available to PHMSA since the Original CAO was
issued as a result of PHMSA’s ongoing investigation. This information includes a visual
examination of the failed pipe section under laboratory conditions, the results of six anomaly
investigation digs and repairs, and a review of previous in-line inspection results, and an
extensive amount of other technical information concerning the pipeline.
Based on this additional information, PHMSA is issuing this Notice of Proposed Amendment to
the Original CAO notifying Respondent of additional preliminary findings of the agency’s
investigation and proposing that Respondent take certain additional corrective measures with
respect to Line 6B.
Additional Preliminary Findings
The preliminary findings in the Original CAO are amended by adding the following additional
preliminary findings:
• The timeline of discovery of the failure is as follows:
07/25/2010 5:56 PM Scheduled shutdown of Line 6B initiated by Enbridge.
07/25/2010 5:58 PM Actual time of pressure drop on pressure logs.
07/25/2010 9:32 PM First of nine 911 odor complaints in area.
07/25/2010 10:54 PM Odor investigation closed by Marshall Township Fire Dept.
07/26/2010 11:18 AM Consumers Energy reports odor to Enbridge Control Center.
07/26/2010 11:45 AM Enbridge personnel confirm leak at rupture site.
07/26/2010 11:45 AM Enbridge emergency response is initiated.
07/26/2010 1:33 PM Enbridge notifies National Response Center – Report #948903.
• On June 4, 2008, Enbridge received the final report on the 2007 MFL inspections results
from the tool vendor. The final report indicated a total of 140 anomalies requiring action
within 180 days, of which 26 were repaired and 114 remain.
• The 2009 in-line inspection using ultrasonic technology identified 250 anomalies, 35 of
which were immediately repaired, and 215 remain. The remaining anomalies are
between mileposts 650 and 753.
• Following the removal and inspection of the failed pipe, Enbridge performed additional
anomaly investigation digs at Mile Posts 611.72, 619.57, 654.42, 654.71, and 682.72. In
some cases, these investigations revealed the presence of anomalies which were repaired.
• On August 21, 2010, an engineering analysis of the deformation anomaly under the St.
Clair River at Mile Post 751.22 performed by a third-party laboratory was provided to
PHMSA.
• PHMSA secured the services of Oak Ridge National Laboratory to provide an
independent review of Enbridge in-line inspection data and support for PHMSA’s review



3
of Enbridge actions. Oak Ridge is analyzing the growth rates of certain identified
anomalies.
• On January 21, 2010, PHMSA issued a Warning Letter to Enbridge related to the
disconnection of five hydrogen permeation internal corrosion monitors installed on Line
6B, one in January 2006, two in May 2006, and two in October 2007. Enbridge reported
that the monitoring systems were disconnected due to communications/instrumentation
problems. The warning noted that Enbridge was not able to prove to PHMSA that its
interim measures properly managed the threat of internal corrosion.
• On January 26, 2010, PHMSA issued an Advisory Bulletin reminding hazardous liquid
pipeline operators of the importance of prompt and effective leak detection capability in
protecting public safety and the environment.
Allegation of Hazardous Condition and Right to Hearing
Section 60112 of Title 49, United States Code, provides for the issuance of a Corrective Action
Order, including amendments, after reasonable notice and the opportunity for a hearing,
requiring the operator of a pipeline determined to pose a hazard to take corrective actions to
protect the public and the environment. These may include the suspended or restricted use of a
pipeline facility, physical inspection, testing, repair, replacement, or other action, as appropriate.
The basis for making a determination that a pipeline facility is or would be hazardous, requiring
corrective action, is set forth both in the above-referenced statute and 49 C.F.R. § 190.233, a
copy of which is enclosed.
After evaluating the all available information on the safety of Line 6B including the foregoing
additional preliminary findings, and considering the nature of the Marshall Failure, the age of the
pipe involved, the manufacturer, the hazardous nature of the product transported, the pressure
required for transporting such product, and the ongoing investigation to determine the root cause
of the failure, it appears that the continued operation of the Line 6B without additional corrective
measures would be hazardous to life, property, and the environment.
Accordingly, PHMSA hereby issues this Notice of Proposed Amendment to the CAO to notify
Respondent of the agency’s intent to issue an Amendment to the CAO requiring the additional
actions specified herein be taken to protect life, property, and the environment. The additional
actions set forth in this Notice of Proposed Amendment to the CAO are in addition to the actions
set forth in the original CAO and do not suspend or eliminate the requirements of the Original
CAO, unless otherwise specifically provided herein.
Response to this Notice
Respondent may request a hearing on this Notice, to be held as soon as practicable, by notifying
the Director, Central Region, PHMSA (Director), 901 Locust Street, Suite 462, Kansas City, MO
64106 in writing within 10 days of service of this Notice. Failure to submit such written
notification waives the opportunity for a hearing and allows the Associate Administrator for
Pipeline Safety to proceed to amend the CAO as proposed. If a hearing is requested, it will be
held telephonically or in-person on a date and in a location mutually acceptable to Respondent
and PHMSA.



4
Amendments to Required Corrective Action
Pursuant to 49 U.S.C. § 60112 and 49 C.F.R. § 190.233 and the terms of the Original CAO,
PHMSA proposes to issue to Enbridge Energy Partners, L.P. this proposed amendment to the
Original CAO requiring the following additional corrective actions be taken with respect Line
6B. Enbridge shall:
1. Restart Plan. Item 2 of the Original CAO is amended by adding paragraphs (D)−(F) as
follows:
(D) Incorporate the actions set forth in PHMSA’s letter of August 10, 2010 including
additional anomaly investigations and hydrostatic testing into the plan.
2
(E) Incorporate the actions set forth in PHMSA’s letter of September 3, 2010 into the
plan.
3
(F) Enbridge must secure the services of a third-party monitor to provide monitoring
during the restart process. Such monitoring shall include monitoring from the
Edmonton Control Center as well as review of start-up procedures and
documentation, pipe design criteria, operating parameters and procedures, process
equipment, monitoring equipment, and SCADA.
2. Integrity Verification and Remedial Work Plan. Item 5 of the Original CAO is
amended by adding paragraphs (G)−(J) as follows:
(G) The plan must include project plans and schedules for the repair of all remaining
anomalies identified for action from the 2007 and 2009 in-line inspections and
identified to PHMSA on September 16, 2010 in accordance with 49 C.F.R. Part
195, but no later than 180 days of restart. Specifically:
i. The 40 remaining 180-day conditions from the 2007 in-line inspection must be
repaired within 180 days of restart beginning with the anomalies identified in
Table 6, of the July 15, 2010, Long Term Pressure Reduction Notification.
ii. The 114 remaining 180-day conditions must be repaired within 180 days of
restart.
(H) The plan must include project plans and schedules for the repair of all other
remaining pipe anomalies identified for action in the July 15, 2010 Notification to
be completed in accordance with 49 C.F.R. Part 195 but no later than 180 days of
restart.
(I) The plan must include the performance of both a transverse field in-line inspection
capable of identifying metal loss and an ultrasonic technology in-line inspection
2 Letter from David Barrett, Director, Central Region, PHMSA to Terry McGill, President, Enbridge Energy
Partners, L.P. dated August 10, 2010.
3 Letter from David Barrett, Director, Central Region, PHMSA to Shaun Kavajecz, Manager, Pipeline Safety
Compliance, Enbridge Pipelines (Lakehead) LLC dated September 3, 2010.



5
capable of detecting cracks on Line 6B. The in-line inspections must be performed
according to the following schedule:
i. The in-line inspection tools must be run within 14 days of restart.
ii. The tool vendor’s initial report on anomalies meeting immediate repair criteria
shall be provided to PHMSA within 30 days of completion of the in-line
inspections.
iii. Immediate repairs as defined by 49 C.F.R. 195.452(h)(4) shall be made within
14 days of discovery regardless of whether such anomaly met a previous
repair criterion.
iv. The tool vendor’s final report on all anomalies shall be provided to PHMSA
within 90 days of completion of the in-line inspections and anomalies
requiring repair shall be repaired in accordance with 49 C.F.R. Part 195 but no
later than 180 days of discovery.
v. The new in-line inspections results must be integrated into results of prior tool
runs to reprioritize the focus and schedule of the integrity verification and
remedial work plan as necessary.
(J) The plan must include project plans and a schedule for the complete replacement of
the pipe in the entire St. Clair River crossing to be completed within one year of
restart. Provide such plans and schedules to both PHMSA and the National Energy
Board of Canada. To the extent delays arise due to obtaining required permits, the
Regional Director may grant an extension of time upon written request.
The actions proposed by this Notice of Proposed Amendment to the CAO are in addition to and
do not waive any requirements that apply to Line 6B under the Original CAO or to Respondent’s
pipeline system under 49 C.F.R. Parts 190 through 199, as applicable, or any other Order issued
to Respondent under authority of 49 U.S.C. § 60101 et seq., or under any other provision of
federal or state law.
After receiving and analyzing additional data in the course of this investigation, PHMSA may
identify other corrective actions that need to be taken. In that event, Respondent will be notified
of any additional measures required and further amendment of the CAO will be considered. To
the extent consistent with safety, Respondent will be afforded notice and an opportunity for a
hearing prior to the imposition of any additional corrective measures.
___________________________________ __________________
Jeffrey D. Wiese Date Issued
Associate Administrator
for Pipeline Safety

320105008H_Region CAO Status Report Restart Plan Disapproved_08102010_text.pdf

VIA CERTIFIED MAIL [70072680 0002 5721 4720] and FAX TO: (713) 653-6711
August 10, 2010
Mr. Terry McGill
President
Enbridge Energy Partners, Ltd
1100 Louisiana, Suite 3300
Houston, TX 77002
Re: CPF No. 3-2010-5008H; Pipeline and Hazardous Materials Safety Administration
(PHMSA) Notice of Disapproval of Restart Plan Submitted by Enbridge Energy, L.P.
(Enbridge) on August 9, 2010
Dear Mr. McGill:
In response to the oil pipeline failure and spill that was reported on July 26, 2010 near Marshall,
Michigan, and the Corrective Action Order issued by PHMSA on July 28, 2010, on August 9,
2010 Enbridge submitted a restart plan for Line 6B and requested approval to restart the pipeline.
Having reviewed the plan and found that it does not adequately provide for the safe restart of the
pipeline, PHMSA disapproves the plan and denies your request to restart the pipeline. The plan
submitted on August 9, 2010 does not contain sufficient technical details or adequate steps to
permit a conclusion that no immediate threats are present elsewhere on the line that require
repair prior to any restart of the pipeline, even at a further reduced pressure.
PHMSA will not approve any restart plan that does not include excavating and exposing
additional pipe and repairing or replacing additional pipe as necessary.
Based on the nature of the failure and the preliminary visual examinations PHMSA made of the
failed pipe section on August 6-7, 2010, PHMSA will not approve any restart plan that does not
include the following:
1. Additional Anomaly Investigations
a. Determine, investigate and remediate as necessary, at least four additional
anomalies in Line 6B subject to similar operating parameters as the anomaly
associated with the pipeline failure. Previous ILI run data must be reviewed and
integrated in light of the new information gained from this failure. Also, the



review must include focus on coincidental features from each of the individual ILI
runs and features coincidental with the failure location. Defect growth rates,
calculated failure pressures, proximity to pump station discharge sections, and
environmental conditions (wet/dry transitions) must be considered for identifying
excavation locations.
b. Provide ILI vendor reports and details of all reviews to PHMSA by 5:00 pm
(EDT) on August 13, 2010.
c. Provide information on the anomalies reported at Mile Posts (MP) 710.74 and MP
751.22, including the nature of the defects, failure pressure calculations, and the
plans for remediation for PHMSA review.
2. Pressure Test
a. Perform a hydrostatic test of the following sections of 6B: MP 607 to MP 610,
and MP 610 – thru the Kalamazoo River - to MP 620.
b. Submit a hydrostatic test plan to PHMSA for review, including associated
pressures, prior to commencement of any hydrostatic test.
3. Provide Additional Clarifications and Requested Changes
a. Define what is meant by “unexpected conditions” as defined in item 1.
Supplemental Monitoring and “abnormal conditions” as noted in Item 4.
Supplemental Patrol of the Right-of-Way
b. Provide detailed procedures related to how start-up of the pipeline will be
achieved,
c. Provide additional detail on the functions of the designated Line Fill coordinator,
such as whether or not this will include manual calculations.
d. Provide a list of all control room and leak detection model improvements (shift
change, use of historical trends to determine unusual pressure signature, column
separation alarms and response, other procedures, display modifications,
communication plan, maintenance, etc) that have been implemented to enhance leak
detection capability.
e. Specify that all communication outages associated with line 6B will be eliminated
before commencing start-up activities.
f. Explain how discharge pressures at Stockbridge and Howell pumping stations
reflect the pressure restrictions required in the Corrective Action Order.
g. Explain how the representative pressures listed in Table 1 determined.
h. Provide the results of any independent metallurgical analysis of the failure pipe to
PHMSA as soon as results are made known, including all drafts of the report.
i. Describe how the in-line inspection tool and batch pig currently located in the
pipeline will be tracked and how this information will be relayed to the control room.
j. Require that Shift Leads/Control Center Supervisors shall only be involved if they
have had previous experience on the Line 6B operator/controller console.
Submit the revised plan to my office by 5:00 pm (EDT) on August 13, 2010 electronically in
Microsoft Word format. Include any supplemental actions Enbridge determines are necessary in
additions to the actions described above. I will then review the revised plan. I may direct



Enbridge to make corrections or additional modifications to the plan. PHMSA reserves the right
to disapprove, comment, or direct modification of any plan provision upon resubmission. Thank
you for your cooperation.
Sincerely,
David Barrett
Director, Central Region, PHMSA
Cc: Shaun G. Kavajecz, Manager, Pipeline Safety Compliance, Enbridge Pipelines
(Lakehead) L.L.C., 119 N 25th Street E, Superior, WI 54880

320105008H_Closure_03202015_text.pdf

CERTIFIED MAIL – RETURN RECEIPT REQUESTED
March 20, 2015
Mr. Bradley F. Shamla
Vice President, US Operations
Enbridge Energy, LP
7701 France Avenue South, Suite 600
Edina, Minnesota 55435
CPF 3-2010-5008H
Dear Mr. Shamla:
On July 28, 2010, the Pipeline and Hazardous Materials Safety Administration (PHMSA)
issued to Enbridge Energy Partners, L.P. a Corrective Action Order in the above-referenced
case. This Order included a requirement to take corrective actions on your pipeline. Based
on our review of the documentation you provided, it has been determined that you have
complied with the terms of this Order.
Accordingly, this case is now closed and no further action is contemplated with respect to
the matters involved in this case. Thank you for your cooperation in this matter.
Sincerely,
Allan C. Beshore
Director, Central Region, OPS
Pipeline and Hazardous Materials Safety Administration
cc: Mr. Andrew J. Harrington, Enbridge, Inc.
Calgary, Alberta Canada
Mr. Jeffrey D. Wiese, Associate Administrator of Pipeline Safety
Washington, D.C.
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